Data Privacy Policy

Last Modified: May 25th, 2018

Thank you for visiting our website and for your interest in our services. Pay with a Tweet services (hereinafter also referred to as "PWAT", “Services” or "PWAT Services") are operated by aklamio GmbH (hereinafter also referred to as "we", "us", "our"). The protection and confidentiality of your data is very important to us.
In this Privacy Policy we inform you about the type, scope, purpose, recipient and legal basis of the personal data processed by us in connection with our services (hereinafter collectively referred to as "Services"), which we offer at www.paywithatweet.com, www.paywithapost.de or other websites or other apps (hereinafter collectively referred to as "Platforms") which incorporate this Privacy Policy. Furthermore we inform you about your rights.
Personal data are all information relating to an identified or identifiable natural person (Art. 4 No. 1 EU General Data Protection Regulation (hereinafter referred to as "GDPR")). This includes information such as your name, e-mail address, postal address or telephone number. Information that is not directly associated with your identity, such as anonymous Internet traffic data (e.g. the number of visits to a website), is not included here.

Who is responsible for the processing of my data?

The person responsible within the meaning of the GDPR and other national data protection laws of the EU member states as well as other data protection regulations is

aklamio GmbH

Hagelbergerstrasse 11

10965 Berlin, Germany

Phone: (030) 20239750

E-mail: support@paywithatweet.com

2. Contact Data of the Data Protection Officer

You can reach our data protection officer at the following contact details:

aklamio GmbH

Hagelbergerstrasse 11

10965 Berlin, Germany

Phone: (030) 20239750

E-Mail: privacy@paywithatweet.com

3. General Information on Data Processing

3.1 Scope of the Processing and its Legal Basis

Please note that use of our platforms is not intended for or directed at persons under the age of 18. We do not knowingly collect personal information from anyone under the age of 18.

We collect and use personal data only to the extent necessary to provide our platforms and services and to ensure their functionality. If the processing of personal data is necessary and such processing is not permitted by a legal basis, we generally obtain the consent of the data subject.

Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 para. 1 lit. a GDPR serves as the legal basis.

In the processing of personal data required for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.

Insofar as the processing of personal data is required to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.

If processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for processing.

3.2 Storage and Deletion of Data

We process and store personal data of the data subject only for the period necessary to achieve the purpose of storage or insofar as this has been provided for by the European Directive and Regulation Giver or another legislator in laws or regulations to which the controller is subject.

If the storage purpose ceases to apply or if a storage period prescribed by the European Directive and Regulation Giver or another competent legislator expires, the personal data is routinely blocked or deleted in accordance with the statutory provisions.

3.3 Recipients of Data

In principle, we only process personal data within our company. If and to the extent that we make use of the services of third parties to provide our services, we will only transfer personal data to such third parties to the extent that the transfer is necessary for the corresponding service and to the extent that a legal basis exists for the transfer.

In the event that we outsource certain parts of data processing (so-called "order processing"), we contractually oblige contractors to process personal data only in accordance with the requirements of the GDPR and the applicable national data protection laws and to guarantee the protection of the rights of the data subject. Information on existing order processing relationships is summarised in Section 6 for the sake of clarity.

4. Data Processing in Detail

In the following we will inform you about the various ways in which personal data is processed, its purpose and legal basis, and how long it is stored.

4.1 Data Processing for General Use of our Services

4.1.1 General Access to our Platforms

We routinely collect a range of general data and information each time we access our platforms. This data is stored in the so-called log files of our system. We may record (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our platforms (so-called referrer), (4) the subwebsites which are accessed via an accessing system on our website, (5) the date and time of access to the Website, (6) the Internet Protocol address (IP address) and the Internet service provider of the accessing system, and (8) other similar data and information used for security purposes in the event of attacks on our information technology systems.

For security purposes, in particular to trace the attack in the event of attacks on our platforms, we store this data including the IP address for a period of seven days and then make the IP addresses anonymous or delete the data. The IP address is required to set up and during the connection to enable the contents of our platforms to be delivered to you. The legal basis for the processing and subsequent storage of the IP address is a legitimate interest pursuant to Art. 6 para. 1 f GDPR. The legitimate interest with regard to the transmission of the IP address lies in the fact that this is necessary for the display of the contents of the respective platform; a display of the website is not possible without the transmission of the IP address. The legitimate interest in limited storage is our security interest.

When using this general data and information we do not draw any conclusions about you as a person. Rather, this information is required to (1) correctly deliver the contents of our platforms, (2) optimize the contents of our platforms and the advertising for them, (3) ensure the permanent functionality of our information technology systems and the technology of our platforms, and (4) provide law enforcement authorities with the information necessary for law enforcement in the event of a cyber attack. This anonymously collected data and information is therefore evaluated by Aklamio both statistically and with the aim of increasing data protection and data security in our company in order ultimately to ensure an optimal level of protection for the personal data processed by us. The anonymous data of the log files are stored separately from all personal data provided by a person concerned. The data will not be passed on to third parties.

4.1.2 Data Processing for Support Services

We provide our platforms with contact options which can be used by our users for electronic contact for information and support purposes. By sending the information you consent to the transmission and storage of the transmitted data to us. In addition, we save the date and time of your contact.

The personal data voluntarily transmitted to us in this context serve us for the processing of your inquiry and the establishment of contact with you. The legal basis for the transmission of data is Art. 6 para. 1 lit. a GDPR. We store the data for this purpose until the conversation with you is finished. The conversation is terminated when the circumstances indicate that the facts in question have been finally clarified and that there will be no further questions, especially in the future.

4.1.3 Cookies

We use so-called cookies and similar technologies on our platforms. For the sake of clarity, the relevant information is summarized in Section 5.

4.2 Data Processing in Connection with the Use of our Services

Aklamio offers you various services with the aim of sharing the added value for our partners created by your recommendations and purchases. If you wish to use our services, you must register with Aklamio and create an Aklamio account under which we process personal data. In this section we inform you about the purposes, the respective legal basis and the storage period of these processes.

4.2.1 PWAT-Account

When registering on our platforms for the purpose of using our PWAT services, we offer you the conclusion of a contract for the use of our services on the basis of our Terms of Use. We collect your e-mail address as well as your name or a freely selectable user name (pseudonym). The e-mail address and your password act as login data for access to your account. For more details on the PWAT account, please see our Terms of Use. In connection with the registration of a PWAT account and the setting of the various functions, we also store your respective IP address and the date and time at the time of registration or the setting of the respective functions.

Data processing within the scope of this contract is carried out for the following purposes

you can make use of our services, in particular to carry out and have carried out a campaign via our platforms;

you can get an overview of the status of your campaigns and an evaluation of the campaign success (only for paid products);

You can upgrade to a paid product;

You can enter and change your payment information;

you can enter and change your address for invoicing.

In connection with every use of the Aklamio account, we automatically process the log-in data in order to prevent misuse or fraudulent use of our services, to defend against attacks on our system and to ensure and verify the proper performance of the contractual services at any time.

The legal basis for the storage and use of your personal data in connection with your Aklamio account is the fulfilment of your contract with us, art. 6 par. 1 lit. b GDPR. If you provide certain profile details voluntarily, such as the posting of a profile photo, your consent is the legal basis, Art. 6 para. 1 lit. a GDPR.

We store your personal data for as long as this is necessary to provide the contractually agreed service. The personal data stored by you in your PWAT account is available to you for the duration of the contract and is stored by us for this period. The personal data will be deleted if you do so in relation to individual data or the PWAT account as a whole, request us to do so accordingly or if the contract ends, i.e. if you or we terminate the contract. Please refer to our Terms of Use for more details.

4.2.2 Objections Against Receiving Commercials

You can object to receiving advertising at any time. If we receive an objection from you to the use of your data for advertising purposes, we can include your personal contact data (name, e-mail address, address, telephone number, fax number if applicable) in a blacklist, with the help of which we ensure that we no longer send you unwanted advertising.

The legal basis is a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. This is to make sure that we can fulfill our obligations from your advertising contradiction. The data will be stored for this purpose until you expressly revoke the advertising objection in writing.

4.2.3 Billing of Chargeable Products

If you subscribe to a paid PWAT product in your PWAT account, we ask for your address, your VAT ID, other payment information and, if applicable - when paying by credit card - credit card information (hereinafter also referred to collectively as "billing data"), depending on the desired payment method. We transfer this data together to our payment service providers for payment processing. In these cases the purpose is to enable the billing of your order. The legal basis is the fulfilment of your contract with us according to art. 6 par. 1 lit. b GDPR. The data is stored for the duration described in Section 4.2.1.

Within the framework of our statutory accounting obligations, we may also transmit accounting data to our accounting offices and tax advisors. We also store the booking documents on which the payments are based, including the payment data contained therein, for a period of ten years in order to fulfil our statutory retention obligations pursuant to § 257 (1) No. 2 HGB and § 147 AO, whereby the period begins at the end of the calendar year in which the booking document arose. The legal basis for such processing is Art. 6 para. 1 lit. c GDPR, the fulfilment of our legal obligations.

4.2.4 Data Processing for Contract Preparation and Execution Purposes

We process personal data for the purpose of contract initiation, contract administration and execution as well as support in the context of ongoing business relationships, so that we can provide our customers with the contractual services and can always guarantee an efficient and profitable use of our services. If the contractual partner is a natural person, the legal basis is that the processing is necessary for the fulfilment of a contract or for the implementation of pre-contractual measures pursuant to Art. 6 para. 1 lit. b GDPR. If we process personal data of employees of the contractual partner, the legal basis is a legitimate interest pursuant to Art. 6 para. 1 sentence 1 f GDPR, namely the facilitation of our business activities and the promotion of the business activities of the customer. There is no conflicting interest on the part of the respective data subject because processing by us within the framework of the existing employment relationship with the data subject is already necessary from the point of view of our customer (§ 26 BDSG-neu). For this purpose we store personal data for the duration of the contract.

We store booking documents resulting from the business relationship for a period of ten years and business letters, i.e. any message relating to the preparation, execution or cancellation of a transaction, for a period of six years, the period beginning at the end of the calendar year in which the business letter was received or sent or the booking document was created. We thus fulfil our legal obligations to store data in accordance with § 257 Paragraph 1 No. 2 HGB and § 147 AO. The legal basis in this respect is Art. 6 para. 1 lit. c GDPR.

4.2.5 Data Processing for Advertising Purposes

There is a contact form on our website which can be used by interested parties for the purpose of making electronic contact. By clicking the "Send" button you agree to the transmission of the data entered in the input mask to us. In addition, we store the date and time of your contact. Alternatively, you can contact us via the e-mail address provided. In this case, the personal data transmitted with the e-mail and our response will be stored. The personal data voluntarily transmitted to us in this context serves us to process your inquiry and to contact you. The legal basis for the transmission of data is Art. 6 para. 1 lit. a GDPR. We use the data for this purpose until the conversation with you is finished. We assume that the conversation will be terminated if the circumstances indicate that the request in question has been finally clarified.

We process personal data of our customers as well as other entrepreneurs and companies not in a business relationship with us and, in this context, also of the employees there as contact persons for the purpose of direct advertising, if legally permissible. If we have not collected the contact data used for this purpose directly from the person concerned, we also take this data from public sources, such as the website of the respective company or profiles of the respective company or employees posted on social networks. The legal basis is a legitimate interest within the meaning of Art. 6 para. 1 sentence 1 f GDPR. The legitimate interest lies in the processing for the purpose of direct advertising itself (see recital 47 GDPR). We store the data for this purpose for the duration of our interest in concluding a contract with the company concerned or until an objection has been declared.

You can object to the processing of personal data concerning you for advertising purposes at any time. You can address your objection at any time to the contact data specified in Section 1. If the advertisement is contained in an e-mail, you can also use the opt-out link contained in it.

4.2.6 Data Processing for Advisory Purposes

We process the personal data of the customer or prospective customer or his employees received in connection with a business relationship or an inquiry of an interested party even after the end of the business relationship or if such a relationship does not come about for the purpose of being able to recommend suitable services on the basis of the previous inquiries or business relationships to our customers or interested parties in the event of a renewed interest in our services. The legal basis is a legitimate interest pursuant to Art. 6 para. 1 sentence 1 f GDPR, the performance of our business activities. In this respect, we store personal data for the duration in which we can expect that the respective customer would like to conclude a further or first contract with us in the future. This is not possible if the customer in question indicates that he will under no circumstances ever enter into a business relationship with us.

4.2.7 Data Processing about the Users of a Campaign

If you use a PWAT campaign, for example by clicking on a PWAT button on a website of the campaign operator, you can participate in the campaign by using one of the following social media accounts:

Facebook account. Facebook-Connect is an offer of the social network "Facebook", which is operated by Facebook, Inc. based in 1601 S. California Ave, Palo Alto, CA 94304, USA (hereinafter referred to as "Facebook"). Use of Facebook is subject to Facebook's Privacy Policy and Terms of Use. When using Facebook, we gain access to the email and other information stored on Facebook that is available in your Facebook profile as public and publicly accessible. Furthermore we get access to your friends list and your newsfeed, unless you contradict the transmission of this data in the setting options on Facebook.

Google+ account. Google+ is a service of Google LLC, 1600 Amphitheatre Parkway,

Mountain View, CA 94043, USA (hereinafter referred to as "Google"). The use of Google+ is subject to Google's Privacy Policy and terms of use. When you use Google, we gain access to the email and other information stored with Google that is available in your Google profile as public and generally accessible. Furthermore, we will gain access to your timeline, unless you object to the transmission of this data in the setting options on Google+.

LinkedIn account. LinkedIn is an offer of LinkedIn Inc, 2029 Stierlin Ct, Mountain View, CA 94043, USA (hereinafter referred to as "LinkedIn"). The use of LinkedIn is subject to LinkedIn's Privacy Policy and Terms of Use. When using LinkedIn, we will have access to the email and other information stored with LinkedIn that is available in your LinkedIn profile as public and generally accessible. Furthermore we get access to your name, your friends list and your timeline, unless you contradict the transmission of this data in the setting options at LinkedIn.

Twitter account. Twitter is an offer of Twitter, Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA (hereinafter referred to as "Twitter"). Use of Twitter is subject to Twitter's Privacy Policy and Terms of Use. When using Twitter, we receive access to the e-mail stored on Twitter and other information that is available in your Twitter profile as public and generally accessible. Furthermore we get access to your timeline and your feed, unless you contradict the transmission of this data in the setting options on Twitter.

LinkedIn account. LinkedIn is an offer of LinkedIn Inc, 2029 Stierlin Ct, Mountain View, CA 94043, USA (hereinafter referred to as "LinkedIn"). The use of LinkedIn is subject to LinkedIn's Privacy Policy and Terms of Use. When using LinkedIn, we will have access to the email and other information stored with LinkedIn that is available in your LinkedIn profile as public and generally accessible. Furthermore we get access to your name, your friends list and your timeline, unless you contradict the transmission of this data in the setting options at LinkedIn.

VK.com. VK.com is an offer of V Kontakte LLC, 1-N, bld. 12-14, Lit. A, Khersonskaya st., St. Petersburg, Russia, 191024 (hereinafter referred to as "VK"). The use of VK is subject to VK's Privacy Policy and Terms of Use. If you use VK, we will have access to the e-mail stored with VK and other information that is available in your VK profile as public and generally accessible. Furthermore we get access to your name, your friends list and your timeline, unless you contradict the transmission of this data in the setting possibilities at VK.

XING account. XING is an offer of XING SE, Dammtorstraße 30, 20354 Hamburg (hereinafter referred to as "XING"). Use of XING is subject to XING's Privacy Policy and Terms of Use. When using XING, we receive access to the e-mail stored with XING and other information that is available in your XING profile as public and generally accessible. Furthermore, we will have access to your name and your friends list, unless you object to the transmission of this data in the setting options on XING.

The data transmitted to us by the respective provider will be processed by us in order to provide you with a post that you can post on the respective social media network in order to receive the bonus offered by the campaign operator. The posting of the link will be communicated to us by the respective network for the purpose of checking the conditions of the premium offer.

You will receive a link after the post has been placed in the timeline of the respective social media network. If you follow this link, you will be taken to the bonus offer. The link is provided in a form shortened by the technology of bitly, Inc, 139 5th Avenue, 5th Floor New York, NY 10010, USA (hereinafter "bitly") so that you can post the link better. As a result, you will be forwarded to the offer via bitly's servers. Individual data is also recorded. With the exception of the IP address, this data is exclusively anonymous. The IP address is not stored by bitly or immediately made anonymous.

The legal basis for the various processing operations is a legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. The legitimate interest lies in the implementation of our business activities.

Your personal data will be stored with us for the period of time during which we can expect technical problems to occur during the collection of the mail or the processing of the services. Furthermore, we store your data for the duration for which you have given us your consent via the respective social media network. You can revoke this at any time.

4.2.8. Data Processing for Statistical and Analytical Purposes

We also use the data collected from our registered users when using our platforms for statistical analyses in order to make our platforms more user-friendly and in particular to improve our services. For this purpose, we use a pseudonymized user ID as well as non-personal, anonymous data that cannot be related to a person by itself or in combination with one another, e.g. in relation to the usage behavior on our platforms or in relation to websites from which the person concerned has accessed our platforms. For these purposes we also process the IP addresses of users in pseudonymised form. With this data alone, a reference to the person concerned can no longer be established.

The anonymous or pseudonymised data will not be combined with personal data about the bearer of the pseudonym without separate express consent and will not be used to personally identify the user of our platforms.

With deletion of the Aklamio account of the affected user, the data processed for the aforementioned purposes will be made completely anonymous, since the pseudonymous user identification then no longer allows any reference to the affected person.

The legal basis for these processing purposes is a legitimate interest pursuant to Art. 6 para. 1 sentence 1 f GDPR, namely the pursuit of our business purposes, the improvement of our offer and the optimisation of our service quality. No conflicting interest can be identified, as the data is already required for contractual performance and identification is no longer possible after the end of the contract.

5. Cookies and Similar Technologies

We use cookies to make the visit to our platforms as attractive as possible and to enable the use of certain functions. Cookies are small text files that are stored on a computer system via an Internet browser. Most of these cookies are only created for one session and are deleted from your hard drive at the end of the browser session. However, other permanently created cookies remain on your computer and enable us to recognize you the next time you visit the website. Unless otherwise indicated below, you can determine the exact storage time of a cookie from the respective cookie by displaying the cookie in your browser.

Furthermore, we use so-called "tags" or "web beacons" in our platforms. These are small graphics (usually only 1 x 1 pixel), which are not visibly integrated into the website and with which certain actions of the page visitors can be measured.

In addition, we use javascript-based codes that are integrated into our platforms to collect certain usage data.

You have the option of generally preventing the storage of cookies by making the appropriate settings in your browser. You can prevent the processing of data using javascript-based codes by deactivating the execution of Javascript in your browser. Although these measures continue to make it possible to visit our platforms, the use of our services and the functionality of our platforms may be restricted.

In the following, we provide specific information about the cookies and similar technologies we use.

5.1 Technical Cookies

On the one hand, we use technical cookies. These are those that are necessary exclusively to collect some information on our platforms in order to provide a service requested or desired by you as a user.

The legal basis for these cookies is a legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR, namely the pursuit of our business purposes. As far as you as a user are affected by these technologies, the legal basis is also the fulfilment of your contract with us, art. 6 para. 1 lit. b GDPR.

5.1.1 Custom Cookies

We use so-called session cookies, which enable a smooth navigation and use of our respective platform (and for example allow access to the Aklamio account) as well as persistent cookies, which enable you to navigate according to some selected criteria (e.g. selection of the national language in which the contents of our platforms are displayed) in order to improve your user experience.

Session cookies are deleted after the end of the browser session, i.e. when you close your browser. Other cookies remain on your device for a specified period of time and enable us to recognize your browser the next time you visit. This way, you do not have to make entries and settings that have already been made again.

We also use cookies, javascript-based codes and web beacons for analysis purposes in order to collect information about the number of visitors and their user behaviour, to increase the security of our systems and to prevent misuse of our platforms.

5.2 Other Third Party Cookies and Technologies

In the following we will inform you about the use of other cookies and similar technologies as well as the respective providers. We will also inform you how you can object to the use of these cookies.

We use the cookies and other technologies listed below and used by us on the basis of Art. 6 Para. 1 S. 1 lit. f GDPR. With the technologies we use, we want to ensure that our platforms are designed to meet the needs of our customers and are continually optimized. On the other hand, we use the technologies for advertising purposes in order to statistically record the use of our website and for the purpose of optimising our offer for you. These interests are to be regarded as legitimate within the meaning of the aforementioned provision.

You can disable the use of cookies by third parties altogether in your browser settings.

5.2.1 Google Analytics

For the purpose of the demand-oriented design and continuous optimization of our platforms we use Google Analytics, a web analysis service of Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter also referred to as "Google"). In this context, cookies and tags are used to create pseudonymous user profiles. The cookie collects data about your use of the platforms such as the browser type/version, the operating system used, the referrer URL (the previously visited page), the IP address of the accessing computer and the time of the server request and transfers it to a Google server in the USA and stores it there.

The data is used to evaluate the use of our platforms, to compile reports on the platform activities and to provide further services for the purpose of tailoring our offering to meet requirements. This information may also be transferred to third parties if this is required by law or if third parties process this data on behalf of the company.

Under no circumstances will your IP address be merged with other Google data. We only use Google Analytics with IP anonymization enabled. This means that the IP address of Google users within Member States of the European Union or in other signatory states to the Agreement on the European Economic Area will be reduced. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

You can prevent the collection of data collected by the cookie and related to your use of the platforms and the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=en). Further information on Google's use of data for advertising purposes, options for settings and objections can be found on Google's websites: "Google's use of data when using our partners' websites or apps", "Google's use of data for advertising purposes", "Manage information that Google uses to show you advertising" and "Determine which advertising Google shows you".

5.2.2 Remarketing and Conversion Tracking

On our platforms, we use Google AdWords and DoubleClick technologies to serve ads based on the use of previously visited pages on our platforms or other websites. Google AdWords and DoubleClick is an offer of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043 (hereinafter "Google"). This enables us to target visitors to our platforms with personalized, interest-based advertising. The websites on which we place such advertising include those of the Google Display Network. To perform the analysis of website usage, which forms the basis for displaying interest-based advertising, we use tags that are integrated into our platforms. These tags are used to store or read a cookie from the advertising network on the user's device. If you subsequently visit another website of the aforementioned networks, you will see advertisements that are most likely related to previously accessed areas of our platforms.

These cookies record which websites you have visited and which offers you have clicked, technical information about the browser and operating system, referring websites as well as the visit time. With the exception of the IP address, which is immediately anonymized, no data will be processed by which you can be personally identified. The data is processed pseudonymously within the framework of this technology, i.e. the relevant data is recorded cookie-related within pseudonymous user profiles; from the perspective of the respective provider, the data is not processed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is.

The information collected by the cookies about your visit to the website is transmitted to and stored by Google on servers. The information will not be merged with other existing personal data about you. We receive no knowledge of the content of the transmitted data and their use by the advertising networks. We can only select which segments of users (e.g. by age, interests) our advertising should be displayed.

We use Google's "Google Tag Manager" to integrate and manage the described tags in our platforms.

The legal basis for such processing is a legitimate interest pursuant to Art. 6 (1) (f) GDPR, namely the pursuit of our business purposes, which also includes the targeted advertising of our services.

We also use the cookies and tags described above to statistically record the use of our platforms and newsletters and to evaluate them for the purpose of optimising our services for you. We collect certain activities, such as calling up or filling out the contact form on our website, to determine whether an advertisement was successful (conversion tracking).

Here, too, the legal basis for such processing is a legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR, namely the pursuit of our business purposes

Google is based in the USA. Insofar as data are therefore transmitted there, this transmission is permitted under Art. 45 GDPR, as Google Privacy Shield is certified and therefore has an adequate level of data protection in accordance with the implementing decision of the Commission (EU) 2016/1250.

You can prevent the use of the cookies described here by using the opt-out option in the Google settings.

5.2.3 Newsletter Tracking

For statistical evaluation of our newsletter campaigns, our newsletter can contain tags with which we can recognize whether and when you have opened an e-mail. Furthermore, we can trace which links were called up in the e-mail. Your IP address will also be recorded. However, this is not stored. No other personal data is also recorded. The legal basis for this processing is a legitimate interest within the meaning of Art. 6 Para. 1 letter f GDPR, whereby the legitimate interest is the evaluation and optimisation of our newsletter. You can object to receiving all types of newsletters at any time by using the opt-out link provided by Duden in the respective e-mails.

6. recipient and use of order processors

We use the services of the contractors listed in this section to provide our services. The legal basis for the use of these contract processors is a legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. The legitimate interest is in the pursuit of our business purposes, in particular the provision of the services described in this data protection declaration. Insofar as we also implement measures to protect the security of personal data stored by us with the involvement of order processors, such as Amazon Webservices Inc, there is an additional legitimate interest in ensuring our technical and organisational measures in this regard. No conflicting interest is apparent, in particular because we have concluded a contract with the respective contractors in accordance with Art. 28 GDPR.

The data is stored by these service providers for the duration for which otherwise storage is legal for purposes according to this data protection declaration, i.e. in particular for the execution of existing contracts, for analysis purposes, for communication or for advertising communication.

6.1 Hosting

For the purpose of hosting our platforms and back-up services, we use the services of Amazon Webservices, Inc, 410 Terry Drive Ave North, WA 98109-5210 Seattle, USA by way of order processing, so that personal data stored on our platforms is transferred to this processor. The data will be processed in the EU and the USA. As far as data are transmitted to the USA and thus to a state outside the EU or the EEA, this transmission is permissible according to Art. 45 GDPR, as Amazon Webservices Inc. is Privacy Shield certified and thus an adequate level of data protection exists according to the implementing decision of the Commission (EU) 2016/1250. The certification can be viewed at https://www.privacyshield.gov/participant?id=a2zt0000000Gn4RAAS&status=Active.

6.2 Support

For support services, we use the services of Zendesk Inc, 1019 Market St., San Francisco CA 94103-1612, USA, on the basis of an order processing relationship. The data is transmitted to Zendesk Inc. in the USA and thus to a country outside the EU or the EEA. This transmission is permitted under Art. 45 GDPR, as Zendesk Inc Privacy Shield is certified as described in Section 6.1 above. The certification can be viewed at https://www.privacyshield.gov/participant?id=a2zt0000000Gn4RAAS&status=Active.

6.3 E-Mail Service Providers

We use the services of the following service providers for sending e-mails on the basis of order processing relationships:

The above-mentioned service providers can receive and process your personal data within the scope of the existing order processing with us. The data is transmitted to the USA and thus to a country outside the EU or the EEA. This transmission is permitted under Art. 45 GDPR, as the provider is Privacy Shield certified, as described above under Section 6.1. The certification can be viewed at https://www.privacyshield.gov/participant?id=a2zt000000000Gn4RAAS&status=Active and https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG.

6.4 Administration and Communication

For internal administration and communication purposes we use Slack Technologies Limited, 4th Floor, One Park Place, Hatch Street Upper, Dublin 2, Ireland, on the basis of an order processing agreement. Slack can receive and process personal customer data within the scope of the existing order processing agreement with us.

6.5 Customer Management

We use the services of Salesforce.com EMEA Limited, Floor 26 Salesforce Tower, 110 Bishopsgate, EC2N 4AY London, UK (hereinafter also referred to as "Salesforce") on the basis of an order processing relationship for customer service and to improve the quality of service for our corporate customers. Salesforce may receive and process personal customer information under our existing order processing agreement. Salesforce provides several tools to analyze indexed content and draw conclusions.

7. What are my rights?

If personal data is processed by you, you are "concerned" within the meaning of the GDPR and you are entitled to the following rights vis-à-vis the person responsible:

7.1 Right to information

You can ask us to confirm whether personal data concerning you will be processed by us.

If such processing is available, you can request the following information from us:

(1) the purposes for which the personal data are processed;

(2) the categories of personal data being processed;

(3) the recipients or categories of recipients to whom the personal data concerning you have been or are still being disclosed;

(4) the planned duration of the storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;

(5) the existence of a right to correction or deletion of personal data concerning you, a right to limitation of the processing by the controller or a right to object to such processing;

(6) the existence of a right of appeal to a supervisory authority;

(7) any available information on the origin of the data if the personal data are not collected from the data subject;

(8) the existence of automated decision-making including profiling in accordance with Art. 22 para. 1 and 4 GDPR and - at least in these cases - meaningful information on the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organisation. In this context, you can request to be informed about the appropriate guarantees according to Art. 46 GDPR in connection with the transmission.

This right to information may be limited to the extent that it is likely to make it impossible or seriously impair the realisation of statistical purposes and the limitation is necessary for the fulfilment of statistical purposes.

7.2 Right to correction

You have a right of rectification and/or completion vis-à-vis the data controller if the personal data processed concerning you are incorrect or incomplete. The person responsible shall make the correction without delay.

Your right to correction may be limited to the extent that it is likely to render the statistical purposes impossible or seriously prejudicial and the limitation is necessary for the fulfilment of the statistical purposes.

7.3 Right to limitation of processing

Under the following conditions, you may request that the processing of personal data concerning you be restricted:

(1) if you dispute the accuracy of the personal data concerning you for a period of time that enables us to verify the accuracy of the personal data;

(2) the processing is unlawful and you refuse to delete the personal data and instead demand the restriction of the use of the personal data;

(3) we no longer need the personal data for the purposes of processing, but you do need them to assert, exercise or defend legal claims, or

(4) if you have filed an objection against the processing pursuant to Art. 21 para. 1 GDPR and it is not yet clear whether our justified reasons outweigh your reasons.

If the processing of personal data concerning you has been restricted, such data may only be processed - apart from being stored - with your consent or for the purpose of asserting, exercising or defending rights or for the protection of the rights of another natural or legal person or on grounds of an important public interest of the Union or a Member State.

If the restriction of the processing has been restricted according to the above-mentioned conditions, you will be informed by us before the restriction is lifted.

Your right to restrict processing may be limited to the extent that it is likely to make it impossible or seriously prejudicial to the fulfilment of statistical purposes and the restriction is necessary for the fulfilment of statistical purposes.

7.4 Right to cancellation

7.4.1 Duty to delete

You may request that the personal data concerning you be deleted immediately and we are obliged to delete this data immediately if one of the following reasons applies:

(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.

(2) You revoke your consent, on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR, and there is no other legal basis for the processing.

(3) You file an objection against the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate reasons for the processing, or you file an objection against the processing pursuant to Art. 21 para. 2 GDPR.

(4) The personal data concerning you have been processed unlawfully.

(5) The deletion of personal data concerning you is necessary to fulfil a legal obligation under Union law or the law of the Member States to which we are subject.

(6) The personal data concerning you have been collected in relation to information society services offered pursuant to Art. 8 para. 1 GDPR.

7.4.2 Information to third parties

If we have made the personal data concerning you public and we are obliged to delete it pursuant to Art. 17 para. 1 GDPR, we will take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform those responsible for data processing who process the personal data, that you as the data subject have requested the deletion of all links to this personal data or of copies or replications of this personal data.

7.4.3 Exceptions

The right to cancellation does not exist insofar as the processing is necessary

(1) to exercise freedom of expression and information;

(2) for the performance of a legal obligation required for processing under the law of the Union or of the Member States to which the controller is subject or for the performance of a task in the public interest or in the exercise of official authority conferred on the controller;

(3) for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;

(4) for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 para. 1 GDPR, insofar as the law referred to under a) is likely to make it impossible or seriously impair the attainment of the objectives of such processing, or

(5) to assert, exercise or defend legal claims.

7.5 Right to Data Transferability

You have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format. In addition, you have the right to transmit this data to another person responsible without obstruction by us, provided that

(1) processing is based on consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and

(2) processing is carried out by means of automated methods.

In exercising this right, you also have the right to request that the personal data concerning you be transmitted directly by a responsible person to another responsible person, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.

The right to transferability shall not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority conferred on us.

7.6 Right of objection

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you, which is based on Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions.

We will then no longer process the personal data concerning you, unless we can prove compelling reasons worthy of protection for the processing, which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct marketing.

If you object to the processing for direct advertising purposes, the personal data concerning you will no longer be processed for these purposes.

You have the possibility to exercise your right of objection in connection with the use of Information Society services by means of automated procedures using technical specifications, notwithstanding Directive 2002/58/EC.

You also have the right to object to the processing of personal data concerning you for statistical purposes pursuant to Art. 89 para. 1 GDPR for reasons arising from your particular situation.

Your right of objection may be limited to the extent that it is likely to make the realization of the statistical purposes impossible or seriously impaired and the limitation is necessary for the fulfillment of statistical purposes.

7.7 Right to revoke the data protection declaration of consent

You have the right to revoke your data protection declaration of consent at any time. The revocation of consent shall not affect the legality of the processing carried out on the basis of the consent until revocation.

7.8 Automated decision in individual cases including profiling

You have the right not to be subject to a decision based exclusively on automated processing - including profiling - that has legal effect against you or significantly affects you in a similar manner. This does not apply if the decision

(1) is necessary for the conclusion or performance of a contract between you and the person responsible,

(2) the legislation of the Union or of the Member States to which the person responsible is subject is admissible and that legislation contains appropriate measures to safeguard your rights, freedoms and legitimate interests; or

(3) with your express consent.

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or g applies and appropriate measures have been taken to protect your rights and freedoms and your legitimate interests.

With regard to the cases referred to in (1) and (3), we will take appropriate measures to safeguard your rights and freedoms and your legitimate interests, including at least the right to obtain the intervention of a person by the person responsible, to state his own position and to challenge the decision.

7.9 Right of appeal to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right of appeal to a supervisory authority, in particular in the Member State where you are staying, working or suspected of infringing, if you believe that the processing of personal data concerning you is contrary to the GDPR.

The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.

7.10. Is there an obligation to provide personal data?

If you create an Aklamio account (see point 4.2.1 above), you must provide certain data within the scope of the contract to be concluded with us. If you wish to withdraw any bonuses credited to your account, you must provide the required withdrawal details. If you make a follow-up request to our support team, you must provide the information necessary to track your order. Furthermore, the provision of personal data is neither required by law nor by contract, nor are you obliged to provide personal data. However, the provision of personal data for the use of our services may also be necessary in individual cases. If you do not provide us with the data we consider necessary, we may not be able to provide our services to you in full.

If you as a corporate customer wish to use our services (cf. above under Section 4.3.1), you must provide certain data within the framework of the user agreement to be concluded with us. We will then point these out in each case. Furthermore, the provision of personal data is neither required by law nor by contract, nor are you obliged to provide personal data. However, the provision of personal data for the use of our services may also be necessary in individual cases. If you do not provide us with the information we deem necessary, we may not be able to provide the services to you in full.

7.11. Amendment of the data protection declaration; change of purpose

We reserve the right to change this data protection declaration in compliance with data protection regulations. The current version can be found here or at any other easily accessible location on our website or platform. If we intend to process data for purposes other than those for which it was collected, we will inform you in advance in compliance with the statutory provisions.